2003 CERES Report

Electric and Gas Industries Form

© 1999 Coalition for Environmentally Responsible Economies

All Rights Reserved. Duplication in any form is prohibited without the express written consent of the publisher.

Contents

1. Company Profile 2

2. Environmental Policies, Organization and Management..... 6

Audits 11

3. Workplace Health and Safety 15

4. Community Participation and Accountability 18

Emergency Response 20

5. Product Stewardship..... 23

6. Supplier Relationships.. 26

Fuel Suppliers 26

Other Suppliers 26

7. Energy Acquisition, Conversion, Distribution, and Sales 29

Electricity 29

Generation 29

Transmission/Distribution 29

Natural Gas 31

Supply 31

Transportation and Distribution 31

Other Energy 32

8. Internal Use and Conservation of Natural Resources 33

9. Emissions and Waste 40

Routine Emissions 40

Spent Nuclear Material. 42

Hazardous Waste 42

Non-hazardous Waste. 45

Accidental Releases 46

Spill Prevention and Leak Detection... 48

Overall Emissions and Waste 48

10. Compliance 49

11. Priorities and Challenges 51

CERES welcomes your comments and feedback on the content and format of our CERES Report form. Please direct any comments or criticism to:

CERES

11 Arlington Street

Boston, MA 02116-3411 USA

(617) 247-0700

(617) 267-5400 Fax

watt@ceres.org

Section 1: Company Profile

(Note: Feel free to provide any additional data or comments that you feel will clarify your answers.

If a question is not applicable, simply state this and provide a brief explanation.)

1-1. Name of Company: Green Mountain Power Corporation

1-2. Contact Person: Dorothy Schnure Stephen C. Terry

Title: Manager, Corporate Sr. Vice President

Communications Corporate and Legal Affairs

Address: 163 Acorn Lane

Colchester, Vermont 05446

Phone: (802) 655-8418 (802) 655-8408

Fax: (802) 655-8419 (802) 655-8419

E-mail: schnure@greenmountainpower.biz; terry@greenmountainpower.biz

Parent Dun & Bradstreet Number: 00-793-9531

Corporate Tax ID Number: 030127430

Corporate Website: www.greenmountainpower.biz

NYSE listing: GMP

1-3. Time period (e.g., fiscal/calendar year) for which information is provided (unless otherwise noted):

Year-end 2003

1-4. Please describe the core activities of your company:

The Company is an investor-owned energy services company located in Vermont that serves one-quarter of the state’s population.

1-5. Total worldwide employees:

2001: 193 2002: 194 2003: 196

Approximate number of full-time personnel assigned to environmental management and technical support worldwide (count those individuals in management positions who spend at least 50 percent of their time working in environmental areas. Identify any contract staff separately.): Green Mountain Power does not have a full time in-house employee designated to environmental. However, Green Mountain Power outsources environmental services.

1-6. Annual worldwide revenue:

2001: $283 million 2002: $275 million 2003: $280 million

1-7. What is your base country, or region, of operations? United States

Please describe regulated service territory, if any:

In 2003, Green Mountain Power had seven work out locations in Bellows Falls, Colchester, Montpelier, Wells River, White River Junction, Vergennes and Wilmington, Vermont.

Please indicate the number of employees in those countries where you have operations:

(Note: The following table is provided for illustration. Use the business sectors and geographic areas defined in your company’s annual report.)

	Electricity				Natural Gas					Other
Region	Gener ation	T & D	Whole sale	Retail	Supply	Trans mission	Distribu tion	Whole sale	Retail	(etc.)
United States	9	91		96
Canada
Mexico, Central America and the Caribbean
Latin America
Asia-Pacific
Western Europe
Central Europe
Former USSR
Middle East
Africa
Other (please specify)

Comments: Green Mountain Power owns and operates 11 generation facilities. These include: one wind plant; eight hydro plants, two of which have fossil generation associated with them; and two fossil fuel plants, all of the plants are located in Vermont. Green Mountain Power has an 11% ownership interest in the McNeil biomass plant in Burlington, Vermont.

1-8. Coverage of information provided in this report, including geographic scope (e.g., all activities, including purchased energy; generation facilities only; wholly-owned and majority-owned facilities):

All activities.

1-9. If all activities are not covered, please describe your projected time-line for including additional aspects of your operations in this report: NA

1-10. Please describe your company’s major business sectors and approximate percent of total 1999 worldwide revenues represented by each. For each sector, please describe the major activities in which your company’s operations are concentrated (e.g., generation/supply, transmission/ transportation, retail sales):

Sector	% Revenues
Electricity (primarily retail sales)	100 (retail sales and generation)
Natural Gas	N/A
Other Energy	N/A
Non-energy	N/A
Total	100%

1-11. Please provide the following information on the scale of your operations. Report generation/supply based on ownership; for transmission/distribution/transportation operations and sales, include both self-supplied (generated) and purchased energy. Note that the same energy may be reported in more than one sector (e.g., electricity that you generate, transmit, and sell).

Sector	Measure of Scale	Amount
Electricity
Generation:	total rated peak capacity (nameplate rating) in MW total MWh generated in 2003	110.0 MW 140,963 MWH
Transmission	km of right of way (69kV and above) total MWh transmitted in 2003	96.6 2,603,654
Distribution:	km of right of way (below 69kV) total MWh distributed in 2003	4,292 1,468,434
Sales:	peak demand in 2003 total MWh sold in 2003 MWh sold to residential customers MWh sold to industrial customers MWh sold to commercial customers MWh sold to other customers (please describe) (street lighting, wholesale sales, sales for resale)	330 MW 4,221,379 MWh 591,047 MWh 645,271 MWh 703,036 MWh 2,284,003 MWh
Natural Gas
Supply:	total production in 1998 (Mm^3) total reserves (Mm^3) underground (natural) storage [not reserves] (Mm^3) LNG storage (Mm^3)
Transportation:	km of pipeline transmission capacity (Mm^3per day) annual throughput in 1998 (Mm^3)
Distribution:	km of distribution network total design day deliverability (Mm^3 per day) total throughput in 1998 (Mm^3)
Sales:	total sold in 1998 (Mm^3) Mm^3 sold to residential customers Mm^3 sold to residential customers Mm^3 sold to residential customers Mm^3 sold to residential customers
Other Energy (please describe)	(define measure of scale)
Non-energy (please describe)	(define measure of scale)

1-12. Briefly describe any significant changes in company structure (e.g., acquisitions and divestitures), sectors, and product lines during the last five years:

During 2002, Green Mountain Power began outsourcing both environmental services and health & safety consulting services. The outsourced firms report to the Green Mountain Power senior management team.

In 2002, Vermont Yankee Nuclear Power Corporation, of which Green Mountain Power owns 20 percent, sold its assets to Entergy Nuclear Vermont Yankee.

In 2002, Green Mountain Power joined with Native Energy to offer its customers CoolHome, a program to fight global climate change by offsetting emission of residential use.

Has the company compensated for these, or other changes (e.g., new regulations), in establishing the environmental data included in this Report? Yes.

Section 2: Environmental Policies, Organization and Management

2-1. List all corporate environmental policies and their dates of issue and/or revision. Detail the geographic scope of these policies and indicate whether the texts of the policies are available to the public:

Policy	Issue Date	Latest Revision	Geographic Scope	Publicly Available?
CERES Principles	Adopted 12/1996	N/A	Company-wide	Yes
Environmental Policy	May 1997	N/A	Company-wide	Yes
Recycling Policy	1992	Spring 1998	Company-wide	Yes
Environmental Management System	1994		Company-wide	No

Please comment on the scope of applicability. If policies are not global, do you have a plan to make them so? Over what time scale? These policies address environmental issues at Green Mountain Power.

2-2. Which of the following are directly addressed by policies or associated guidance documents? Specify where not applicable to your company:

Environmental		Health & Safety
Water Quality	√	Emergency Planning	√
Air Quality		Personnel Safety	√
Energy Conservation Opportunities		Transportation Safety	√
Solid/Hazardous Waste	√	Materials/Equipment Safety	√
Storage Tanks	√	Industrial Health/Hygiene	√
Chemical Releases	√	Occupational Medicine
Spill Prevention	√	Other (specify)
Site Remediation
Chemical Inventory Reporting	√
Resource Use
Other (specify)

2-3: Please describe your company’s approach to the issue of sustainability, focusing on the following three elements:

• How does it apply to your industry?

Edison Electric Institute is the association of shareholder-owned electric companies, international affiliates and industry associates worldwide. EEI describes four major steps the electric utility industry is taking to reduce the impact of electricity on the environment. It makes note of the four facts below:

The electric industry is:

1. “…leading all U.S. industries in taking voluntary actions to mitigate green house gases.”

2. “…reducing our air emissions significantly, even as demand for electricity increases.”

3. “…using a broad mix of fuel sources to generate electricity and are leaders in developing new ways to produce electricity more cleanly and efficiently.”

4. “…promoting consumer technologies to meet the growing demand for electricity while simultaneously protecting the environment.”

In 2003, EEI and its member companies began a sustained effort to promote environmental principles for all member companies.

• What does it mean for your company?

Sustainability at Green Mountain Power involves the ability to achieve solid financial results while protecting the earth’s natural systems and ensuring quality of life for people. We enable this by considering economic, social and environmental issues in our daily business activities and business planning processes.

• How is your company making progress toward it?

ECONOMIC
- Strong and routine investments in the infrastructure
- Selling services (Utility Services Business)
- Strong and transparent customer focus
- Employee Stock Ownership Program
- Competitive return on assets and equity
- Strong and transparent customer focus
- Effective cost management
- Accountability
- Selling services
- Rapid development & deployment of technology
- Maximize value of supply chain
- Manageable / lean number of vendors

ENVIRONMENTAL
- Environmental compliance
- Routine measurement & scorecard reporting
- Routine audits (Internal & External)
- Regulatory calendar
- Building strong, proactive & transparent relationships with
all stakeholders
- Environmental management systems
- Automated plant maintenance (Environmental Mgmt. System)
integrated with daily work scheduling
- Green House Gases strategies
- CCX
- Generation investments
- Fleet improvements (biodiesel, hybrids)
- Green house gas protocol
- Carbon offsets (Colchester bldg.)
- Renewable energy
- 40% water, wood, wind
- Cool Home carbon offsets for customers
- Searsburg -- largest commercial wind farm in NE
-Sustainable development reporting
- CERES Report
- CCX audit & reporting
- Annual Shareholder’s Report
- Integrated Resource Plan
- FERC Reports
- Research & development report on wind
- Community Fund
- Nature conservation programs
- Current Use Program – Forest Management Programs
- Osprey program
- Green Mountain Trail work
- Winooski River clean-up
- Land conservation effort in the Winooski Valley River Basin
- Land farming / oil composting
- No herbicides
- Mycotech research as another alternative to herbicides

SOCIAL
- Access to electricity
- Warmth Fuel Fund
- Power Partners
- Strong customer relationships
- Provide reliable service
- Northeast Reliability Project
- Strong investment in T & D
- Scorecards
- Aggressive vegetation management
- Storm response
- Service Quality Guarantees
- Support key community programs
- WARMTH
- Community Fund
- Green-Up Day sponsor
- United Way
- Employee volunteerism encouraged
- Community leadership
- Supportive of employees’ families
- Consult stakeholders… transparency
- Energy Fair
- Customer focus groups
- Chamber events & involvement
- External stakeholder plan
- Editorial board meetings
- Ethical business practices
- Code of ethics
- Transparent press relations
- ISS rating
- Employee health, safety, pay and benefits
- Flex time
- Smoking cessation (Smoke Free Workplace)
- SHARP Program
- Safety audits
- Scorecards
- Stock ownership program
- 401(k) / health benefits
- IHMS / on-site massage
- Health club discounts
- Showers in workplace
- Employee Assistance Program
- 100 mile challenge

2-4. Are your company's policies reviewed periodically to ensure their continuing relevance in light of changing standards, technology, and emerging concerns? Yes.

Explain:

2-5. What level of management is responsible for maintaining the currency of your corporate environmental policies and practices? Senior management.

Explain: Environmental policy is developed at the senior management level by the Senior Vice President for Corporate and Legal Affairs. The primary responsibility for environmental compliance is executed at the middle management level. During 2002, Green Mountain Power began outsourcing both environmental services and health & safety consulting services. The outsourced firms report to the Green Mountain Power senior management team.

2-6. Is there an officer specifically designated with environmental responsibilities? Yes.

Explain: The Senior Vice President of Corporate and Legal Affairs is ultimately responsible for the environmental program at Green Mountain Power.

2-7. Are there updates to senior management, the Board of Directors, or a committee of the Board of Directors concerning the company's environmental activities? If yes, with what frequency? Yes.

Explain: The Senior Vice President of Corporate and Legal Affairs updates the senior management team periodically throughout the year, as warranted. The senior management team informs the Board of Directors.

2-8. Are environmental compliance and operational decisions principally handled in centralized or decentralized fashion? Decentralized.

Explain: Since both environmental services and health & safety consulting services are outsourced, the Green Mountain Power management team routinely meets with outsourced firms and discusses environmental compliance issues.

2-9. How is accountability for environmental performance organized in your company?

Accountability for environmental performance occurs in several ways at Green Mountain Power. First level managers who have had extensive training in environmental, health and safety issues are responsible for compliance at the operational or field level. They, in turn, are accountable to senior staff up through the ranks so that senior managers at the vice president level share ultimate responsibility for implementation of the environmental program.

At the same time, accountability is tied to the various functional groups within the Company. Each operational unit has training and compliance responsibilities unique to it. Supervisory staff in each operational unit is accountable to senior management who reviews the Company’s performance.

2-10. Is outstanding environmental performance of teams, operating units and individuals recognized internally?

Yes.

If yes, how does such recognition occur (e.g. salary review, bonus, promotion, award, etc.)?

Green Mountain Power authorizes managers to award individual employees bonuses for extraordinary performance.

2-11. Are your employees encouraged to take the initiative, submit suggestions for improvement, and to suggest actions or policies that reduce the company’s environmental impact? Yes.

Explain; if yes, give specific examples of methods used to encourage employee initiative:

Green Mountain Power uses an electronic publication called the “Update.” This regular update report encourages employee suggestions and questions on all subjects, including environmental issues. Questions are directed to the proper employee for a response and an answer is returned in a short period of time.

2-12. A) Does your company have, or provide access to, educational programs in which employees with environmental responsibilities participate to update their skills and knowledge? Yes.

Explain; if yes, give specific examples:

As stated in previous reports, one of the Company’s strengths is the nature and extent of on-going educational programs that are designed to promote environmental awareness and responsibility among workers. To date, this training has involved the majority of operational workers involved with fieldwork. Educational topics range from the regulatory requirements and procedures for hazardous materials, universal waste and solid waste management, and spill response procedures. Green Mountain Power encourages stewardship through recycling programs and voluntary waste minimization.

Training programs involve all field personnel, who receive a minimum of two hours and as many as 20 hours of environmental, health and safety training on an annual basis. The training programs include a review of spill response procedures, emphasizing spills containing PCBs or spills that may affect “navigable waters of the United States.” The programs also include specific training pertinent to emergency response procedures at Green Mountain Power’s generating stations and compliance issues related to the handling, transport and storage of Company-generated hazardous, regulated, universal and solid wastes. Mock tabletop and field drills are performed in compliance with Federal OPA-90 regulations annually at our large generation facility where #1 fuel (kerosene) capacity exceeds 2,000,000 gallons.

The Health and Safety component of the training program includes hazardous communications, which focus on methods and observations for detecting the presence of hazardous chemicals or materials. It also focuses on use of Material Safety Data Sheets and other markers that may be important for understanding an emergency situation. These classes are presented upon initial assignment and are reviewed every three years thereafter.

B) Does your company have educational and informational programs in which all other employees participate to update their skills and knowledge and ensure their understanding and implementation of the company’s environmental policies? Yes

Explain; if yes, give specific examples of nature of program, frequency, and percentage of employees reached:

As noted above in response 2-11, the “update” provides an effective clearinghouse for the kind of information that these questions address. It is particularly effective because it is able to reach and serve all Green Mountain Power personnel on a timely basis, thus providing consistent information to all workers simultaneously.

As Green Mountain Power continues to incorporate the CERES Principles into its way of doing business, such education and information-exchange opportunities will be expanded and improved.

2-13. A) Does your company sponsor scientific or policy research devoted to environmental technology, management, and performance issues, or other relevant research areas, at educational or research institutions? Yes.

Explain; If yes, provide up to three specific examples:

• Green Mountain Power received a grant from the US Department of Energy and the Electric Power Research Institute to support Green Mountain Power’s construction and operation of its Searsburg Wind Generating Station. The facility was part of the turbine verification program, which meant it was considered a research facility for the first three years of its operation. Lessons learned during construction and operation of the turbines were shared with the industry through the turbine verification program.

· The study of a biological alternative to herbicides: Green Mountain Power is testing the use of a naturally occurring fungus to control undesirable vegetation near power lines. In the fall of 2001 and in 2002, we applied Myco-Tech^TM at a two-acre site in Duxbury. The fungus is a non-chemical alternative to herbicides that we hope will be economical and more effective than manually clearing, as Green Mountain Power does not use herbicides. Preliminary assessment after one year shows that the fungus has an effect on the growth, but needs further study before it can be determined whether it will be effective. In 2003 we continued to monitor the effectiveness of the product as vegetation grows in the test area and untreated area. An additional test is to be conducted elsewhere in the state. We are anticipating final EPA approval for unrestricted use in 2004

· GMP has developed “demand response” programs in cooperation with the New England-ISO to defer or avoid use of electricity. These programs will encourage participation by small commercial and residential customers as well as large industrial customers. Green Mountain Power customers provide approximately 90% of the demand response in Vermont. Green Mountain Power has worked closely with utility regulators and other utilities to develop the programs and overcome various technical challenges related to delivering the programs.

B) Does your company participate in external activities designed to share the results of such scientific and policy research? Yes.

Explain; if yes give specific activities and noteworthy accomplishments:

GMP readily shares its knowledge of new technologies with customers, utility regulators and other utilities.

2-14. To what degree does your company use internal environmental cost information to support internal decision-making? Is this done through a managerial cost accounting system or other financial management system, which routinely compiles, analyzes, and reports on environmental costs?

In either case, give examples of;

• Which environmental costs (e.g., management costs, resource use, waste disposal, permitting, monitoring, training, auditing, insurance);

• At what level (e.g., product, process, facility, division, corporate):

Green Mountain Power has established a separate responsibility center for its environmental, health & safety department. Payroll and O&M costs are thereby tracked. The O&M budget accumulates training and travel costs, along with outside service costs, expendable equipment charges, industry dues, subscriptions, waste disposal, spill clean-up, publications, state and federal fees, plant improvements related to spill prevention etc. The payroll budget picks up the employee working in the designated environmental cost center or those who cross-charge the cost center for work on environmental projects. A separate project number can be set up by the EHS manager to track costs according to specific projects, products and so on.

For what purpose is this cost information compiled?

The senior management team uses the data to evaluate the effectiveness of environmental programs, track budgets, and evaluate environmental cost benefit.

Please describe any successes or challenges experienced in developing/applying this system. How did these experiences compare to your expectations?

The environmental cost center contains environmental expenses previously accounted for by various cost centers at various locations. Centralizing environmental cost in its own cost center has afforded Green Mountain Power the ability to centrally monitor environmental cost, achieve a cost savings on expenditures, and provide data enhancing corporate environmental management.

If such a system is not in place, are there plans underway to create an environmental cost tracking system? If not, why not? If plans do exist, what steps toward implementation have been made?

2-15. Does your company normalize environmental information (e.g., chemical release, energy usage, greenhouse gas emissions) by an activity unit within the company (e.g., per unit of output, per unit of input, per labor hour, per employee)?

No. Data is tracked in each associated area and is compiled centrally for this report.

If yes, please describe the approach adopted. What successes or challenges were faced in developing/applying these normalization techniques? How did these experiences compare to your initial expectations?

If no, does your company have plans to do so in the future? If not, why not?

Waste management is tracked at a facility-by-facility basis and quantified annually. Waste management practices and waste generation reports are analyzed and evaluated to determine the effectiveness of waste management practices. Annual waste management practices and waste generation reports are compared to previous years data to establish waste generation trends. These trends are used in the planning process for waste management practices and training in the upcoming years.

AUDITS

2-16. Does your company have programs for workplace health, safety and environmental auditing? Yes.

Explain; if yes, describe these programs, including audit frequency, scope of audits, and structure (e.g., consolidated health, safety and environmental audits, or separate audits):

Workplace Health and Safety:

Safety field audits, with the focus on health and safety, are performed for employees on an ongoing basis. The minimum goal is to audit each employee once each year.

Facilities audits are performed on a monthly basis. The focus of facility audits are to identify potential losses related to operational, safety or environmental deficiencies.

Environmental

In 2003 Green Mountain Power recognized the need for an Environmental Management System (EMS) to facilitate environmental compliance and auditing. The framework of the EMS was developed in 2003 and the system will be implemented in 2004. The EMS will include all of the programs listed below.

Power generating facilities, service centers and substations were audited quarterly for environmental compliance. At a minimum, the audits included the following programs:

Spill Prevention Control and Countermeasure (SPCC) Plan (40 CFR Part 112)

SPCC regulated facilities have cumulative oil storage greater than 1,320 gallons, and at the site, there is a potential for an oil spill to reach wetlands and/or waterways. At Green Mountain Power, SPCC applies to power generating facilities, service centers, and the majority of substations. In accordance with Green Mountain Power’s SPCC Plan, all SPCC regulated facilities are inspected twice per month. The scope of the inspections included a visual survey of oil storing equipment, its condition, containment structures, and a check for leakage. Spill response materials are inventoried and inspected.

Oil Pollution Act (OPA) 90 Plan (40 CFR Part 112)

OPA 90 regulated facilities have a cumulative oil storage capacity greater than 1 million gallons. OPA establishes facility specific spill scenarios and emergency procedures in case of a catastrophic oil spill. At Green Mountain Power, OPA applies to only the Berlin #5 fossil fuel generating facility.

In accordance with Green Mountain Power’s OPA 90 Plan, the Berlin #5 facility is inspected weekly. The scope of the inspection includes recording information relative to the tank, oil storage equipment, and oil containment structures.

The plan also requires Green Mountain Power to annually inspect the roof of the tanks, calibrate gauges, evaluate pumps, valves, the cathodic protection system, and low pressure fuel cut off systems.

Lastly, the plan requires Green Mountain Power to inspect the tanks in accordance with API 653 every five years.

State of Vermont Small Quantity Generator of Hazardous Waste

In accordance with the State of Vermont Hazardous Waste Management Regulations, Green Mountain Power facilities that generate between 220 pounds and 2,200 pounds of hazardous waste are classified as Small Quantity Generators (SQG) of hazardous waste. In 2003, two facilities were classified as SQG, the Colchester and Montpelier Service Centers. In accordance with State of Vermont regulations, these facilities were inspected daily. The scope of the inspection included the visual observation of containers, labels, container storage areas, and general hazardous material management.

Annually, waste generation reports for all facilities are evaluated to determine State of Vermont generation status. Facility generation status is updated annually at the State of Vermont.

State of Vermont Conditionally Exempt Generator of Hazardous Waste

In accordance with the State of Vermont Hazardous Waste Management Regulations, Green Mountain Power facilities that generate less than 220 pounds and 2,200 pounds of hazardous waste are classified as Conditionally Exempt Generators (CEG) of hazardous waste. In 2003, 13 facilities were classified as CEG. Green Mountain Power conducts quarterly inspection of these facilities. The scope of the inspection included the visual observation of containers, labels, container storage areas, and general hazardous material management. Inspections of CEGs are not required by the Vermont Hazardous Waste Management Regulations.

Oil/Water Separators

For the past several years, Green Mountain Power has maintained its oil/water separator systems. These systems are located at service centers, at transformer pad storage areas, and at select power generating facilities. These systems include floor drains, trench drains, sedimentation chambers and oil/water separators. Annually, these separators are pumped out, cleaned and inspected for integrity. Data obtained during the inspection is contained in a binder specifically for oil/water separator maintenance.

Toxic Substances Control Act (TSCA) 40 CFR 761

In 2003, Green Mountain Power managed PCB waste at TSCA storage facilities located at the Montpelier and Colchester Service Centers. The TSCA storage facilities were maintained, inspected and audited in accordance with 40 CFR 761. Daily inspections include visual observations of each container, labels, and container audits. Annually, TCSA waste reports are submitted to the EPA.

Stormwater Management

Stormwater at the Colchester Service Center is managed under a State of Vermont stormwater management permit. In accordance with the permit, stormwater appurtenances and parking areas are inspected quarterly, parking areas are swept and catch basins are cleaned annually, and an annual report is submitted to the State of Vermont.

Hydraulic Lifts

Green Mountain Power maintains one in-ground hydraulic lift each at the Colchester and Montpelier Service Centers. Quarterly, the hydraulic lift pits are inspected for leaks and debris. The hydraulic lifts at each facility are cleaned on an as-needed basis.

Underground Storage Tanks

Green Mountain Power maintains vehicle fueling stations at the Colchester and Montpelier Service Centers. Each fueling station consists of two underground storage tanks (USTs), two fuel dispensers and a tank monitoring system. The USTs are managed in accordance with the State of Vermont Underground Storage Tank Regulations codified at 10 VSA Chapter 59 including inspections and testing.

2-17. Are your audits conducted by company personnel or outside individuals/organizations?

An outsourced firm performs environmental audits. Green Mountain Power personnel routinely perform facility inspections and employee safety audits.

If both, what is the ratio of company personnel to outside auditors?

Approximately 50% of environmental audits are outsourced. Green Mountain Power performs approximately 90% of health & safety audits.

2-18. Do your audit programs apply worldwide? No.

Explain:

Green Mountain Power operates only in the State of Vermont.

2-19. Are your audit systems administered on a company-wide basis, on a site basis, or on the basis of distinct operations?

Explain; give details of sites and operations audited:

Environmental audits were administered on a company-wide basis. Power generating facilities and service centers were audited quarterly.

2-20. Which of the following are part of your audit (inspection) programs?

Environmental		Health & Safety
Compliance	√	Compliance	√
Management Systems	√	Management Systems	√
Spill Prevention	√	Emergency Planning	√
Water Quality	√	Personnel Safety	√
Air Quality	√	Transportation Safety	√
Solid/Hazardous Waste	√	Process Safety Management	√
Storage Tanks	√	Materials/Equipment Safety	√
Chemical Releases	√	Industrial Health/Hygiene	√
Site Remediation	√	Occupational Medicine
Chemical Registration/Certification		Other (specify)
Resource Use
Other (specify)

Comments: Refer to the response to Item 2-16.

2-21. Does your company have an internal energy audit program for identifying conservation opportunities and progress? Yes.

Explain: The Company, like all utilities in Vermont, supports the Energy Efficiency Utility, a state-sponsored efficiency utility that was formed in 2000 to coordinate and operate most of the state’s electric utility energy conservation programs. We also use the services of the efficiency utility in our facilities.

2-22. Are the results of your audit findings reported to senior management and/or the board of directors? Yes.

Explain:

Senior management reviews major audit findings.

2-23. What areas (divisions, operations) of your company have been audited over the last two years?

The environmental and health & safety program was audited by an outside firm in 2001.

2-24. Are your audit programs reviewed by an independent organization? Yes.

An independent firm audited all programs.

If yes, does the review include the following:

Program Content – Yes.

Site Selection – All sites in general.

Coverage – Complete.

Frequency – Not specified.

Protocols – All programs, audits, compliance etc.

Audit Team Selection - Determined by independent firm.

Reporting of Results - Reported to CEO.

Corrective Action Planning and Tracking – All recommendations were implemented ASAP

Other

Please identify outside reviewer, if publicly available:

If no, are there plans underway to utilize an independent review in the future?

Not at this time.

2-25. Are your audit results available to the public? Records are stored, but can be made available.

2-26. Describe other notable aspects of your company's environmental policies, organization, and management not otherwise covered in this section:

Management at Green Mountain Power has made a serious commitment to Vermont’s environment by reducing risks related to potential oil/fuel discharges to waterways. In 2003, these improvements included the construction of spill containment structures at 11 substations.

Section 3: Workplace Health and Safety

3-1. Briefly describe your company’s activities in the area of workplace health and safety. Give examples of specific programs, accomplishments, awards and/or training activities, etc., that go beyond the requirements of the law:

Green Mountain Power has maintained low injury rates for 2003. Rates continue to be below the historical average for Green Mountain Power and below industry average for electric utilities.

The Health & Safety program consists of training, employee audits, and equipment purchases. Constant analysis reveals where problems exist. Special attention is focused on such areas.

A positive corrective action policy has emphasized coaching in areas where infractions of safety rules occur. However, there are mechanisms in place to permit progressive discipline where serious problems may exist.

Green Mountain Power has an aggressive back-to-work policy. Injured employees come back on light duty as soon as permitted by their physicians.

Office workstations are evaluated on a regular basis to ensure proper ergonomic positioning. All stations are adjustable to accommodate the individual needs of employees. An ergonomics policy also addresses field positions.

Hardhats, safety glasses and steel toe boots are required to be used at all times in the field, even when there isn’t a specific hazard exposure. The purpose is to encourage a habit of wearing this protective equipment so it will be used when needed. These rules also apply to all contractors working on Green Mountain Power facilities.

Green Mountain Power has an effective safety committee consisting of four management and five field personnel. The committee examines all accidents and injuries for root cause and determines if changes are necessary to prevent future injuries. They also look at procedures, training requirements and equipment needs or modifications.

Public safety has been significantly addressed through a new non-profit organization founded by Green Mountain Power. Vermont Utilities for Electrical Education, Inc. (VUEE) was founded in the end of 2000 with members comprised of Vermont utilities and managed by a Board of Directors made up of safety individuals from seven utilities throughout Vermont. By the end of 2001, more than 13,000 pieces of educational material related to electrical safety were sent to Vermont schools.

Safety orientations are required and conducted for all new field operations employees before they are exposed to any work.

How are these programs and other workplace health and safety related-related information communicated to employees?

Green Mountain Power updates employees through monthly meetings and e-mail communication and broadcast of the Executive Safety Committee minutes.

3-2. A) Does your company communicate with workers on health and safety-related information by, for example, sharing internal safety audits, internal compliance audits, etc.? Yes.

When audits occur, a discussion follows with the overall findings, emphasizing not only the violations, but the areas of compliance as well. Communications through email that is accessible to all employees occurs on a regular basis.

Bulletin boards are located in each district office and have updated safety information posted constantly.

B) Does your company provide, or is it willing to provide, workers with the following information about specific facilities?

	Provide	Willing to Provide?	Not Applicable
Chemical release data (please specify)	X
Chemical use and storage data (including radioactive material)		X
Worst case accident scenarios	X
Internal safety audits		X
Internal compliance audits		X
Material transportation risks (including radioactive material)	X
Process hazards analyses	X
Pollution prevention plans	X
Other information gathered for the CERES Report	X

Comments:

The Company is forthcoming with all information related to these kinds of risks and risk evaluations. As part of Green Mountain Power’s on-going program to reduce risk and improve communications, among both its employees and the greater community, it shares information, as it becomes available, with those who would benefit most.

3-3. What challenges and successes has your company experienced in the area of workplace health and safety?

One challenge is keeping up with the many constantly changing rules and regulations related to environmental, safety and health.

3-4. Provide information on workplace safety performance using normalized measures such as lost days. Provide such information for a base year, 2000, 2001, 2002 and a target year:

Year	Injuries	Lost Days	Fatalities	Incidence Rate
1994 (Target)	1	2	0	0.28
2000	3	9	0	1.49
2001	2	14	0	1.56
2002	5	61	0	2.20
2003	6	30	0	2.61

Explain: The incidence rate is calculated to reflect the rate of lost time injuries and can compare with any industry or any number of employees. For comparison, the lost workday incidence rate for our Standard Industrial Code (SIC) 49 was 2.4 in 1998.

3-5. Do you use other measures for workplace health and safety performance? Please explain and give trends:

Each injury or vehicle accident is entered into a database. From that database, reports can be generated to reflect the type of injury, age group of the injured employees, locations where these injuries occur, specific department performance, etc. With this data, an accurate determination can be made regarding the type and amount of training that is needed to improve performance and decrease injuries.

3-6. Describe other notable aspects of your company’s workplace health and safety not otherwise covered in this section:

The Executive Safety Committee consists of nine members, 50% or more are union personnel representing various field positions. This committee has had an enormous impact on improving the safety awareness throughout the company and has identified numerous safety hazards that have been quickly rectified.

Section 4: Community Participation and Accountability

4-1. Does your company have a policy/procedure to consider community impacts in its decision-making?

As a company that operates in a regulated environment, most major decisions receive a comprehensive review in the public arena. Through formal and informal channels, the Vermont Department of Public Service and the Vermont Public Service Board, as well as other regulatory agencies, comment on Green Mountain Power proposals on behalf of the Vermont public. In some cases formal public hearings serve as a forum for comments.

Green Mountain Power’s formal and informal policies encourage employees to solicit public input from a variety of channels.

The company is involved in a stakeholder process to expand its wind station at Searsburg, New England’s only operating wind farm.

In May 2004, Green Mountain Power announced it would hold a series of meetings over the next 18 months to discuss Vermont’s Energy Future. Green Mountain Power will use what it learns from the public discussions to help determine its actions in the future.

Does this policy provide for direct community involvement? If so, with which groups? How are these groups chosen? Yes. See descriptions above and below in this response.

How is this involvement organized (e.g., through community advisory panels, public hearings, newsletters, regular meetings, open forums)?

Green Mountain Power’s public is quite well defined – it consists of approximately 89,000 electric customers. For Green Mountain Power to succeed its customers must understand the business and the issues it faces. The Company’s monthly letter to customers delivers timely information on company successes, decisions that face the Company’s employees, and the results of the decision-making processes.

4-2. Does your company proactively seek the advice and counsel of independent community groups (e.g., through newsletters, regular meetings, open forums, or community oversight committees) regarding possible risks posed by your operations? Yes.

Explain: The nature of Green Mountain Power’s business requires us to do this. The communications that are required are met through regulatory requirements, contingency plans, and other mandated notifications procedures. Cases where additional risk communications might be necessary would be construction or demolition work at a plant or facility. In this instance, the Company’s facility manager works with the local planning commission to assure that all permits, notifications and other requirements are met. These situations are rare, but they are covered through Green Mountain Power’s standard protocols regarding notification and communications within communities where Green Mountain Power operates.

4-3. Are employees encouraged to participate in community activities aimed at improving environmental quality?

Green Mountain Power employees have participated in two significant cleanup activities where trash has been accumulating for many years, including cleaning up a section of the Winooski River and the Howe Farm in Burlington, where Green Mountain Power was involved in a wetlands restoration project . In addition, employees packed food at the Vermont Foodbank.

Explain; if yes, give specific examples of methods used to encourage such activities and noteworthy results:

Green Mountain Power solicited employees for volunteers.

4-4. List up to three community-oriented environmental activities sponsored by your company:

1. Green Mountain Power offers tours of its wind and hydro facilities. Each year, we organize a school day at the Searsburg wind generating plant, and several times a year we offer tours to the public. Green Mountain Power frequently takes groups of school children through our hydro plants.

2. Green Mountain Power has used its network of hydroelectric dams to improve fishing and the fishery in the Winooski River, the primary waterway in its service territory. Improvements include voluntary minimum-stream flows, fish passages, and trap-and-truck operations.

4-5. What challenges and successes has your company faced in the area of community participation and accountability?In 2004, Green Mountain Power began planning a series of community meetings to discuss Vermont’s Energy Future. The challenge will be to stimulate an informed discussion while truly remaining open to what we learn in the meeting.

In September 2004, Green Mountain Power held its first Community Energy Fair at its headquarters in Colchester, attracting almost 400 people. With the bucket rides, dancing to bluegrass music, pole-top rescue demonstrations, winning prizes in the energy quiz, playing the Energy Hog game, it seemed that there was something fun for everyone. We intend to continue this effort to reach out to the community to help educate about energy and the environment in a fun setting.

4-6. How are environmental considerations incorporated into your company’s public policy activities?

The Company’s corporate mission statement includes a strong commitment to environmental protection; the Green Mountain Power Board of Directors in 1997 adopted an environmental policy that tracks consistently with the CERES Principles; the Company uses an environmental screen in evaluating all power sources; Green Mountain Power supported successful efforts to create a statewide Energy Efficiency Utility; and, as a key part of human resource policy, all field personnel at Green Mountain Power are required to undergo extensive and continuing training in environmental protection

4-7. Environmental justice refers to actions in support of populations most negatively affected by environmental factors, as they tend largely to be those populations most vulnerable due to economic, political, racial or other factors. In support of the goals of environmental justice, describe if and how your company ensures protection of particularly vulnerable or at-risk groups in communities directly affected by your activities:

Several factors provide assurance that when such issues arise, they will be handled in an appropriate manner. First, Green Mountain Power is a relatively small organization with a responsive management team that is sensitive to environmental and social issues. Secondly, the State of Vermont is extremely sensitive to environmental issues. And finally, compared with other electric utilities, Green Mountain Power engages in relatively few activities that have significant negative environmental impacts.

4-8. Does your company provide, or is it willing to provide, the following information about specific facilities to communities in which company operations are located?

	Provide	Willing to Provide?	Not Applicable
Chemical release data (please specify)		X
Chemical use and storage data (including radioactive material)		X
Worst case accident scenarios		X
Internal safety audits		X
Internal compliance audits		X
Material transportation risks (including radioactive material)		X
Process hazards analyses		X
Pollution prevention plans	X
Resource conservation plans			X
Other information gathered for the CERES Report		X

Comments:

EMERGENCY RESPONSE

4-9. Does your company have trained personnel and equipment capable of handling chemical emergencies that your plants might experience, including those that might involve radioactive materials? Yes.

Explain: Green Mountain Power has trained personnel, and spill response materials stored at its facilities necessary to respond to releases of oil and hazardous materials. Primarily, Green Mountain Power stores petroleum-based materials, which are not federally regulated. At SPCC regulated facilities, Green Mountain Powers manages its materials in accordance with the site-specific SPCC Plan, which specifies storage practices, maintenance requirements, potential spill scenarios, spill pathways, emergency response actions, spill response equipment storage locations and inventory, emergency contacts and a list of spill response contractors. Green Mountain Power personnel are trained in spill response practices, and emergency response preparedness, annually.

Assuring that Green Mountain Power has personnel capable of using the equipment necessary to respond to a large spill at any of Green Mountain Power’s power production plants is one of the main training responsibilities of the EHS Manager. This manager develops and conducts extensive training annually and works to assure that the Company’s personnel can respond to most emergency situations quickly and effectively. The Company also keeps an active roster of outside consultants and emergency response agencies apprised of the type and magnitude of potential problems that could occur at its larger facilities.

Training programs incorporate emergency response personnel into training sessions to ensure that emergency response personnel are familiarized with oil spills of various sizes, plant operations, and cleanup procedures. This has afforded both Green Mountain Power personnel and outside services a degree of confidence that will be beneficial in actual emergency response situations.

4-10. Does your company conduct training exercises with firefighters and rescue teams in all communities where research and development and production facilities are located? Yes.

Explain: In municipalities where Green Mountain Power stores bulk oil/kerosene, and in municipalities where Green Mountain Power has facilities categorized as a Small Quantity Generator of hazardous waste, Green Mountain Power has notified appropriate municipal representatives of these activities and routinely communicates with municipal representatives.

At Green Mountain Power’s two largest power generating facilities, Green Mountain Power conducts emergency response drills, which include fire departments, emergency response contractors, Green Mountain Power personnel, and other emergency response groups.

4-11. Does your company keep local emergency responders informed of risks created by, or chemicals used by, your operations? Yes.

Explain: Please refer to responses 4-9 and 4-10. In addition, Green Mountain Power submits SARA Title III Tier Two reports as required by the Community Right-to-Know and SARA Title III programs. These reports are submitted to the Division of Emergency Management, the Local Emergency Planning District, and local fire department.

Gasoline, diesel fuel, kerosene and battery acid within active battery banks are the only materials that are stored in sufficient quantities applicable to the Community Right-to-Know and SARA Title III programs.

4-12. Are the neighbors at your plant sites informed of the existence of any procedures and evacuation plans that may be needed in case of an incident? No.

Explain: Based on the geographic location of Green Mountain Power power generating facilities, relative to the surrounding population density, Green Mountain Power has not implemented emergency evacuation plans. However, if a catastrophic event occurred, Green Mountain Power would rely on Green Mountain Power personnel, emergency response contractors and municipal responders to support evacuation of affected areas.

4-13. Describe other notable aspects of your company’s involvement with communities directly affected by your activities not otherwise covered in this section:

Green Mountain Power is involved in public Safety Awareness Days, and is an active participant on Safety Councils for various state and national organizations.

Green Mountain Power’s EHS Manager is an active member of several safety organizations and is the President of the Vermont Utilities for Electrical Education, Inc.

Section 5: Product Stewardship

5-1. Does your company have a formal policy requiring an environmental, health, and safety evaluation of its new and existing energy products and services (e.g., rate structures, “green” power offerings, conservation services)? Not at this time.

If yes, how can this be obtained by the public?

5-2. Does your company have procedures in place to monitor the commitments it makes in this policy?

Explain: See response to 5-1.

5-3. Has your company instituted procedures to assist energy product and service designers create products or services (e.g., rate structures, green power offerings, energy efficiency services) with the potential for lowered environmental impact? Green Mountain Power has made arrangements with Native Energy and Clean Air-Cool Plant to enable our customers to make contributions through their Green Mountain Power bills to help CA-CP fight global warming. Customer contributions result in the retirement of renewable energy credits and help new resources to be built.

If yes, which of the following are considered?

• Fuel Source

• Conversion Efficiency

• Level of Use

Comments:

5-4. What are the major positive and negative environmental and safety impacts potentially associated with the use or misuse of services and products your company provides its customers? (Note: do not include impacts of production or supply here.)

Reliable electrical service has a positive impact on public safety. It has become a necessity in today’s society and has significant repercussions when unavailable.

In some circumstances public safety may be directly jeopardized by damage to power lines (i.e., ice storm damage, wires down, trees on lines, etc.).

If possible, estimate this impact for products sold over the last three years (e.g., injuries resulting from product use):

Several electrical high voltage contacts have occurred with excavators, dump trucks and other construction equipment. No fatalities resulted.

Describe any programs or procedures designed to prevent or minimize any such misuse:

There are two ways to misuse electricity: one is to waste it when it can be used more efficiently and the other is to use it in an unsafe manner. To ensure that customers use electricity safely, Green Mountain Power regularly communicates with its customers using bill inserts. Specific messages are targeted to parents for teaching their children about electrical safety, to construction workers so they may be more aware of overhead lines when they work at a site, to people cutting trees ensuring that they check for power lines nearby as well as offering frequent messages for electrical safety around the home. Green Mountain Power’s EHS manager also conducts training for children in our schools, contractors using excavators, emergency services personnel and other places with exposure to power lines. Vermont Utilities for Electrical Education, Inc., also has a significant school outreach program for electrical safety education.

5-5. Describe demand side management, energy efficiency services, or other “green” service activities undertaken by your company (e.g., energy audits, weatherization programs). Provide information on the number of customers served:

Green Mountain Power’s last year to deliver DSM programs was 1999. The goal of Green Mountain Power's 2000 DSM activities was to manage the transition from utility administered DSM to the new concept of a statewide Energy Efficiency Utility (EEU).

We currently keep our Call Center personnel and commercial account representatives informed regarding programs offered by the statewide Energy Efficiency Utility.

Green Mountain Power’s web site includes “My Home,” a tool whereby customers can create a simple layout of their home, add the appliances they use every month, and My Home calculates their usage and compares it to their most recent bill. This tool helps customers learn how their usage habits affect their bills.

Green Mountain Power continues to respond to customer inquiries regarding high usage, renewable energy and net metering. Net metering is allowed in Vermont for small renewable energy sources such as photovoltaic and small wind turbines.

5-6. Describe consumer energy efficiency and environmental education programs undertaken by your company.

Consumer energy efficiency education is now primarily the function of the Energy Efficiency Utility (EEU). This is funded by a surcharge on every electric bill. Green Mountain Power responds to technical questions if our customers choose to contact us. We refer them to the EEU if they have detailed questions about incentive programs.

Information on home energy use, energy saving tips and links to other sources are available on Green Mountain Power’s Internet website.

5-7. Does your company’s rate structure promote reduced consumption? If so, how?

Yes. Green Mountain Power sets the retail price above the marginal cost, which sends the proper price signals to reduce use where necessary.

5-8. What challenges and successes has your company faced in the area of product stewardship?

Green Mountain Power offers space in our customer newsletter to the Energy Efficiency Utility for information on energy efficiency. We also offer the Energy Efficiency Utility opportunities to include coupons and other materials in with our bills to promote Energy StarÔ lights, washers and refrigerators.

5-9. Describe other notable aspects of your company's product stewardship activities not otherwise covered in this section:

Green Mountain Power makes a conscious effort to use power from renewable resources, rather than fossil fuels. The 2003 fuel mix demonstrates the extent to which we were successful:

Hydro: 35.4%, nuclear: 37.4%, oil: 2.7%, gas: 1.3%, wood: 3.5%, wind: 0.5%, opportunity purchases (can’t break down by fuel): 19.2%

This power supply both reduces air emissions and preserves natural resources for future generations.

Section 6: Supplier Relationships